U.S. Department of Transportation

Federal Railroad Administration

Office of Railroad Safety

Office of Railroad Development

Version 1.0

November 2009
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Contents 

Preface to Version 1.0 ........................................................................................................................................iii

Introduction.............................................................................................................................................................. 1

The History of High‐Speed Rail ..................................................................................................................... 1

Safety and High‐Speed Rail Going Forward............................................................................................. 1

Strategy........................................................................................................................................................................ 5

1.  Prevention ........................................................................................................................................................ 6

a.  Vehicle Track Interaction ...................................................................................................................... 6

b.  Positive Train Control............................................................................................................................. 8

c.  Grade Crossing Safety.............................................................................................................................. 9

d.  Maintenance‐of‐Way Safety Management .................................................................................. 12

e.  Right‐of‐Way Safety .............................................................................................................................. 13

f.  Real‐Time System Monitoring........................................................................................................... 14

2. Mitigation........................................................................................................................................................ 14

a.  Structural Standards............................................................................................................................. 14

b.  Cab Car Forward..................................................................................................................................... 17

c.  Fuel Tank Integrity ................................................................................................................................ 17

3.  Emergency Management......................................................................................................................... 18

4.  System Safety Programs .......................................................................................................................... 18

Next Steps................................................................................................................................................................ 21

Appendix A: Current Requirements and Open Issues...................................................................... 23

Appendix B: Potential Tier Structure for Passenger Systems................................................... 25
    

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Preface to Version 1.0

The Federal Railroad Administration (FRA) initially issued the High‐Speed Passenger Rail 

Safety Strategy (Strategy) on July 24, 2009.  The first version was a Discussion Draft for 

Public Outreach.  FRA distributed the Strategy to Rail Safety Advisory Committee 

participants and asked the industry to provide comments by August 28, 2009.  Comments 

were received from 20 different organizations.  All comments were reviewed and, where 

appropriate, incorporated in this, the final version of the High‐Speed Passenger Rail Safety 

Strategy.  

Many organizations commended FRA for developing a high‐speed rail (HSR) strategy.  They 

congratulated FRA for their proactive and progressive approach.  The commenters 

acknowledged the vision that the Strategy provided and appreciated FRA providing a clear 

regulatory framework approach for the introduction of high‐speed rail in the United States.  

Other commenters provided advice on items that FRA should consider as they developed 

new rules or standards contemplated in the Strategy.  Commenters were concerned with a 

variety of issues such as energy efficiency, train weights, and excessive axle loading and its 

affect on the viability of high‐speed rail.  Other commenters recommended methods to 

determine safety equivalency and encouraged FRA to use scientific risk management and 

safety cases in their evaluation of HSR equipment and systems.  Still others offered to 

generously share information on train control systems, HSR equipment, and other 

technology from around the world that currently supports the safe and efficient operation 

of HSR systems.  All the suggestions and offers for assistance are appreciated and will be 

considered as the Strategy moves forward. 

The commenters were united in their desire to limit grade crossing exposure.  Although 

FRA’s current policy is to allow highway‐rail grade crossings for train speeds up to  

125 mph, some commenters asked that all grade crossings be eliminated at speeds above 

110 mph.  One commenter used the French approach as an example.  The French ban grade 

crossings when train speeds reach 100 mph and enhance grade crossing equipment for 

corridors with train speeds between 80 and 100 mph.   

Several commenters were concerned about commercial and legal issues.  FRA received many 

questions regarding who pays and who is ultimately responsible for the operating concepts 

that FRA has discussed in the Strategy.  Freight operators, for example, brought up several 

concerns related to sharing track and corridors with high‐speed passenger rail.  They 

remarked that infrastructure improvements and associated ongoing maintenance would be 

costly and risk and liability arising from passenger operations would amount to an 

unwarranted subsidy of passenger railroads.   They also stated that constructing a dedicated 

right of way for high‐speed passenger rail along an existing freight corridor would limit the 

ability of the freight railroad to access customers on the passenger rail side of the corridor.   

Freight railroads may also be affected by other obligations including requirements for right‐

of‐way plans and real‐time failure monitoring. Other commenters asked who would pay for 

improvements to grade crossings and other systems to support HSR.   
iv 

Although these are important issues, they are primarily commercial issues that cannot be 

addressed in this Strategy.  The appropriate method to settle these and other commercial 

or legal issues and to answer the questions posed here is through appropriate operating 

agreements between the freight operators and the passenger railroad. These requirements 

and potential affects on the freight railroad should not be overlooked when negotiating 

operating agreements. 

Finally, some commenters requested that FRA expand the scope of the Strategy activities to 

cover additional subject areas including defining barrier treatments for separation of 

corridors, defining hazardous material and school bus route requirements, defining 

guidelines for perimeter protection, addressing protection of rail lines from vehicles falling 

from overpasses, and other safety‐related activities.  FRA agrees that these are valid 

concerns that deserve consideration.  However, the Strategy presented here represents 

FRA’s view of the most important elements that should be addressed immediately to 

support the development of HSR in the Nation.  The other issues that have been offered are 

important but not as high a priority as the issues already identified in the Strategy.  

However, these and other issues may be added to the Strategy in the future as FRA begins 

to make progress on the most important initiatives.  
1 

Introduction

The History of High‐Speed Rail 

Fostering the development of high‐speed rail (HSR) and other intercity passenger service 

in the United States has been an important part of the work of the Federal Railroad 

Administration (FRA) since its creation in 1967.  During the 1980s and 1990s, FRA played a 

central role in managing and facilitating the growth of high‐speed rail service on the 

Northeast Corridor.  Acting in response to the Intermodal Surface Transportation 

Efficiency Act of 1991 (ISTEA), FRA began the formal process of designating HSR corridors 

for future development and providing limited funding for corridor improvements directed 

primarily at safety.  With the passage of the American Recovery and Reinvestment Act of 

2009, which provided $8 billion in capital assistance for HSR corridors and intercity 

passenger rail service, and following President Obama’s announcement of a strategic plan 

for high‐speed rail (“Vision for High­Speed Rail in America”), FRA now takes on the 

important work of helping to make high‐speed rail a reality in markets across the Nation. 

Although the focus of this High‐Speed Passenger Rail Strategy (Strategy) is developing HSR 

service on new corridors, inevitably this strategy needs to consider implications for other 

intercity passenger service, commuter rail service, and regional rail projects that seek to 

provide transit‐like service on rail lines shared with conventional passenger or freight 

trains.  Further, any HSR operation will include track segments where only conventional 

speeds are possible.  Flexibility provided for the first time in connection with HSR may also 

be relevant to service at conventional speeds.  Accordingly, other forms of passenger rail 

service are referenced to the extent necessary to attain consistency and clarity.     

On June 17, 2009, FRA’s Administrator issued a notice of funding availability and interim 

program guidance for the HSR and Intercity Passenger Rail Program (74 FR 29899; June 

23, 2009).  The guidance identified transportation safety and safety planning as evaluation 

criteria for merit consideration of proposed projects and programs.  This Strategy 

describes how FRA will provide specificity and additional safety guidance for the 

development of HSR systems. 

Safety and High‐Speed Rail Going Forward 

   

The hallmark of world‐class, high‐speed rail is safety.  FRA believes that railroads 

conducting HSR operations in the United States can provide service as safe as, or safer than, 

any HSR operation being conducted elsewhere.  FRA also believes that the expansion of 

HSR in America will yield safety benefits for those who choose to use the service instead of 

driving the same distance via roads and highways.  Data published by the National Safety 

Council shows that, based on miles traveled, personal motor vehicle travel is 12 to 20 times 

more likely to result in a fatality than passenger rail travel.     

In anticipation of such service, and to promote public safety, FRA has developed this 

Strategy, which includes: (1) establishing safety standards and program guidance for HSR, 
2 

(2) applying a system safety approach to address safety concerns on specific rail lines, and 

(3) ensuring that railroads involved in passenger train operations can effectively and 

efficiently manage train emergencies.  This Strategy endeavors to achieve uniformly safe 

rail passenger service, regardless of speed.  Since the severity of collisions and derailments 

increases with speed, safety performance targets for preventive measures are tiered to 

become more stringent as speed increases. 

Current FRA regulations include Tier I equipment safety standards for passenger trains 

operating at speeds up to 125 mph.  FRA established additional standards (Tier II) for high‐

speed trains that operate up to 150 mph.  These Tier II requirements address 

crashworthiness, crash energy management, vehicle suspension systems, brake systems, 

train configurations and other elements critical for high‐speed trainsets.  The Tier II 

standards only impact the Amtrak Acela Service on the Northeast Corridor because Acela is 

currently the only Tier II application operating in the United States.  Existing FRA track 

safety standards are comprehensive and specify track geometry and cant deficiency for 

FRA Classes 1 through 9 at speeds up to 200 mph.  The track standards include 

requirements for Class 6 track (110 mph) and above for remote monitoring of carbody 

acceleration and truck hunting, and equipment qualification on actual routes.  Appendix A 

provides a representation of current requirements and open issues related to track safety 

standards.  

FRA is currently reviewing European and worldwide equipment standards and developing 

guidance for high‐speed trains operating at up to 220 mph.  FRA is also exploring 

improvements and expansions to vehicle and track safety standards through rulemaking.  

Currently, the agency is advancing rules that amend the Passenger Equipment Safety 

Standards and Track Safety Standards for high‐speed train operations and train operations 

at high cant deficiencies to promote the safe interaction of rail vehicles with the track over 

which they operate.  The rulemaking would revise the safety limits for these operations 

and the processes to qualify them, and account for a range of vehicle types.  Although this 

rulemaking would substantially change FRA’s regulations governing the safety of high‐

speed and high cant deficiency train operations, a number of the changes would codify FRA 

decisions affecting such operations made under current approval and waiver processes.  It 

would therefore reduce some existing regulatory burdens while safely facilitating the 

broader introduction of high‐speed operations and enabling lower‐speed train operations 

to gain efficiencies through operation on curved track at higher cant deficiencies. 

FRA will continue to promote safety and facilitate the introduction of new HSR operations.  

President Obama proposes to help address our new transportation challenges by investing 

in an efficient HSR network of 100‐ to 600‐mile intercity corridors that connect 

communities across America.  This vision builds on successful highway and aviation 

development models with a 21st century solution that focuses on a clean, energy‐efficient 

option (even today=s modest intercity passenger rail system consumes one‐third less 

energy per passenger‐mile than automobiles).  FRA expects that each HSR operation will be 

appropriately tailored to its operating environment.  The High‐Speed Rail Strategic Plan 

divides potential operations into four categories or generic descriptions:  
3 

 HSR – Express.  Frequent express service between major population centers 

200B600 miles apart, with few intermediate stops.  Top speeds of at least 150 mph 

on completely grade‐separated, dedicated rights‐of‐way (with the possible 

exception of some shared track in terminal areas).  Intended to relieve air and 

highway capacity constraints. 

 HSR – Regional.  Relatively frequent service between major and moderate 

population centers 100B500 miles apart, with some intermediate stops.  Top speeds 

of 110B150 mph, grade‐separated, with some dedicated and some shared track 

(using positive train control (PTC) technology).  Intended to relieve highway and, to 

some extent, air capacity constraints. 

 Emerging HSR.  Developing corridors of 100B500 miles, with strong potential for 

future HSR Regional and/or Express service.  Top speeds of up to 80B110 mph on 

primarily shared track (eventually using PTC technology), with advanced grade 

crossing protection or separation.  Intended to develop the passenger rail market 

and provide some relief to other modes. 

 Conventional Rail.  Traditional intercity passenger rail services of more than 100 

miles with as little as 1 to as many as 7B12 daily frequencies; may or may not have 

strong potential for future high‐speed rail service.  Top speeds of up to 79 mph 

generally on shared track.  Intended to provide travel options and to develop the 

passenger rail market for further development in the future. 

Additional strategies for mitigating risk will probably be necessary depending on the 

specific operating environment.  FRA generic HSR definitions represent minimum 

baselines and do not preclude HSR operators, host railroads, or the FRA from defining 

additional appropriate requirements. 
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5 

Strategy

FRA currently administers a comprehensive set of safety standards for conventional and 

high‐speed service.  The standards include requirements for track, equipment, operating 

rules and practices, signals and train control, communications, emergency preparedness, 

certification of locomotive engineers and control of alcohol and drug use, among others.  As 

HSR service expands, portions of those standards will require updating and augmenting. 

Going forward, FRA will also incorporate lessons learned from the work that has been 

underway on high‐speed corridors since the enactment of ISTEA.  This Strategy provides a 

framework for documenting lessons learned and integrating the necessary actions, and 

seeks to achieve the following purposes: 

 Support a very high level of safety for new passenger rail service. 

 Focus on safety results and flexibility to meet service needs while achieving those 

results. 

 Ensure alignment between safety requirements and passenger rail funding policies. 

To ensure adequate safety for HSR, FRA intends to utilize appropriate safety standards and 

to apply system safety program techniques to enhance safety while meeting transportation 

objectives.    

FRA expects a significant increase in the number of HSR operations.  Each HSR operation 

will operate in a different environment, and each will have different needs based on that 

environment.  As a result, FRA anticipates a variety of proposed HSR operations that will 

consist of a combination of different types of equipment, different degrees of isolation from 

known hazards, and different safeguards.  To maintain safety, FRA will need to have 

minimum safety standards or guidelines that apply clearly to a variety of operating 

environments, and a reliable method to assess the safety of a new operating environment.  

To allow FRA to more easily facilitate the evaluation and application of standards to 

specific operations, it will be helpful to group substantially similar operations together 

when possible.  The four categories of HSR listed above can be used as a starting point for 

grouping similar operations.  Additional factors that will be used to group similar 

operations include: 

 The presence or absence of freight traffic, the volume of freight traffic, and the 

nature of freight operations (e.g., overhead vs. local switching). 

 The degree to which passenger equipment used on the corridor(s) is of similar 

construction. 

 The degree of isolation of the passenger system from other hazards (e.g., incursions 

of motor vehicles due to proximity of roads and bridges, the degree of security that 

can be established on the right‐of‐way, and the presence of natural hazards such as 

seismic events or high water).  
6 

Through this strategy, FRA proposes to define categories or “tiers” of rail passenger service 

tied to maximum operating speeds and the aforementioned factors.  Safety requirements 

and guidance would then be matched to that structure.  Appendix B provides a visual 

representation of how that might be accomplished. 

1.  Prevention 

FRA already has a long history administering an extensive set of regulations designed to 

prevent accidents and injuries.  These regulations address track, equipment, railroad 

operating rules and practices, qualification and certification of locomotive engineers, 

control of alcohol and drug use, and other subject matters.  Forthcoming regulations will 

address bridge safety and medical fitness‐for‐duty of safety‐critical employees, among 

other topics.  However, there are specific additional refinements and actions that need to 

be taken to address the needs of HSR service. 

a.  Vehicle Track Interaction

The Track Safety Standards (49 CFR Part 213) specify requirements for nine classes of 

track based on maximum allowable speed.  The standards for higher speeds focus on 

vehicle‐track interaction as well as track geometry, rail integrity, and appropriate 

inspection practices.  The Passenger Equipment Safety Standards (49 CFR Part 238) 

contain complementary requirements for qualification of high‐speed passenger equipment. 

Based upon results of research and recommendations of the Railroad Safety Advisory 

Committee (RSAC), FRA is finalizing a proposed rule that would establish updated vehicle‐

track interaction safety standards, largely unifying the requirements in a single part of the 

Code of Federal Regulations and making it easier to qualify new equipment.  The proposal 

would revise existing limits for vehicle response to track perturbations and add new limits 

where necessary.  The proposal accounts for a range of vehicle types that are currently in 

use and may likely be used on future high‐speed or high cant deficiency rail operations (or 

both) and provides safety assurance for train operations in all classes of track.  The 

proposal is supported by the results of simulation studies designed to identify track 

geometry irregularities associated with unsafe wheel forces and acceleration, thorough 

reviews of vehicle qualification and revenue service test data, and consideration of 

international practices.

High‐speed track safety standards are based on the principle that, to ensure safety, the 

interaction of the vehicles and the track over which they operate must be considered 

within a systems approach that provides for specific limits for vehicle response to track 

perturbation.  From the outset, FRA strove to develop revisions that would serve as 

practical standards with sound physical and mathematical bases, account for a range of 

vehicle types that are currently used and may likely be used on future high‐speed or high 

cant deficiency rail operations (or both), provide safety assurance for train operations in all 

classes of track, would not present an undue burden on operators, and would be verifiable 

by field measurements.   
7 

The proposed standards are based on safety principles that apply to trains of all speeds and 

cant deficiencies.  For trains operating at higher speeds with greater cant deficiencies, the 

safety risk is increased.  Accordingly, the application of the same safety principles to trains 

operating at higher speeds with greater cant deficiency will result in more stringent 

standards.  FRA’s proposal addresses the following key areas: 

 Revise— 

o Qualification requirements for high‐speed or high cant deficiency operations, or 

both. 

o Acceleration and wheel force safety limits. 

o Inspection, monitoring, and maintenance requirements.  

o Track geometry limits for high‐speed operations. 

 Establish— 

o Necessary safety limits for wheel profile and truck equalization.  

o Consistent requirements for high cant deficiency operations covering all track 

classes. 

o Additional track geometry requirements for cant deficiencies greater than  

5 inches. 

 Resolve and reconcile inconsistencies between the Track Safety Standards and 

Passenger Equipment Safety Standards, and between the lower‐ and higher‐speed 

Track Safety Standards. 

Through the close examination of these issues, the RSAC Task Force developed proposals 

intended to result in improved public safety while reducing the burden on the railroad 

industry where possible.   

Although the RSAC Task Force did not recommend revising or retaining standards for  

Class 9 track, FRA has subsequently identified the continued need for benchmark 

standards addressing the highest speeds likely to be achieved by the most forward‐looking 

potential HSR projects.   To that end, FRA and Volpe have conducted additional research 

and vehicle‐track interaction simulations at higher speeds and concluded that Class 9 track 

standards can be safely extended to include the highest contemplated speed proposed to 

date.  FRA will include those benchmark standards in its forthcoming Notice of Proposed 

Rulemaking (NPRM) to revise the Track Safety Standards and continue discussions with 

the RSAC Task Force as comments are addressed.  However, FRA intends that the Class 9 

standards remain only as benchmarks with the understanding that the final suitability of 

track standards for HSR–Express will be determined only through examination of the 

entire operating concept, including the subject equipment, track, and other system 

attributes. 

FRA will issue proposed and final rules on vehicle­track interaction and other key safety issues

related to track and structures as soon as possible.
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b.  Positive Train Control  

The Rail Safety Improvement Act of 2008 (RSIA)1 reauthorizes and enhances FRA=s safety 

programs.  Notably, from an intercity passenger rail development perspective, the RSIA 

requires implementation of PTC2 systems on every main line over which intercity rail 

passenger or commuter rail passenger service is regularly provided.  Each Class I railroad 

carrier and each regularly scheduled intercity or commuter railroad must install PTC 

systems by December 31, 2015, governing operations on: (1) its main line over which 

intercity rail passenger or commuter rail passenger service is regularly provided, (2) its 

main line over which hazardous materials that are poisonous‐ or toxic‐by‐inhalation are 

transported, and (3) such other tracks as the Secretary designates by regulation or order.  

Addressing the practical requirements of this provision remains a financial challenge for 

passenger rail operators; however, it has always been understood that HSR requires very 

competent train control as an integral element of system planning and execution. 

With help from the RSAC, FRA has prepared a proposed rule that will implement the RSIA 

PTC requirement.3  Although PTC requirements are specified to support intercity and 

commuter passenger train service in all speed ranges, the proposed rule will address high‐

speed service (described as any service operating at speeds greater than 90 mph) in 

specific speed bands, with increased system capability required as operating speeds 

increase.   

In anticipation of high‐speed service—and to ensure public safety—FRA is proposing 

tiered requirements for PTC systems.  The performance thresholds are intended to 

increase safety performance targets as the maximum speed limits increase to compensate 

for increased risks, including the potential frequency and adverse consequences of a 

collision or derailment.  These requirements are cumulative as speeds increase.  At speeds 

of 60 mph and above, the system would need to incorporate the safety‐critical functions of 

a block signal system with fouling circuits and broken rail detection.  For territories where 

operating speeds are greater than 90 mph, the PTC system must also be shown to be fail‐

safe (although comment will be solicited regarding the characteristics of onboard freight 

PTC equipment for Emerging HSR), and “perimeter protection” must be established to keep 

unauthorized movements (e.g., trains, unsecured rolling stock) off the railroad.  The 

potential consequences of a collision or derailment for railroads operating above 125 mph 

are even greater.  In addition to meeting the requirements under the previous two 

categories, such railroads exceeding 125 mph must also provide an additional safety 

analysis supporting the sufficiency of the PTC technology to support a level of safety 

comparable to similar transportation service and must include analyses demonstrating 

that opportunities for incursion into the right‐of‐way (e.g., vandalism, motor vehicles 

                                                       

1  Public Law No. 110‐432, Division A, enacted Oct. 16, 2008.

2  APositive Train Control@ means a system designed to prevent collisions between trains, overspeed 

derailments (derailments caused when a train exceeds speed limits), incursions into established work zone 

limits (i.e., for roadway workers maintaining track), and the movement of a train through an improperly 

positioned switch.

3  74 FR 35950; July 21, 2009. 
9 

deviating from adjacent roadways) have been addressed through prevention and/or 

detection and warning.  (See also 49 CFR § 213.361 (Right‐of‐way plans for Class 8‐9 track), 

discussed below.)  The capability of PTC systems to provide detection and warning of 

incursions from trespassers or motor vehicles is an important feature that can assist a 

railroad to demonstrate an appropriate level of incursion protection.   At speeds that 

exceed 150 mph, PTC functionalities would be described within an overall plan subject to 

FRA approval.  

  

FRA will finalize standards for PTC systems by the end of November 2009.

c.  Grade Crossing Safety  

Highway‐rail grade crossings pose inherent hazards to train operations, as they do to 

motor vehicles.  Accordingly, existing FRA regulations require that train operations at 

greater than 110 mph be supported by plans designed to physically restrain motor vehicles 

from becoming a derailment hazard, and above 125 mph, no at‐grade crossings are 

permitted (49 CFR § 213.347).   

There have been demonstrated successes in deploying “sealed corridor” technology on 

designated HSR corridors.  The most mature of these corridors is on the North Carolina 

Railroad, the route of intercity passenger service sponsored by the North Carolina 

Department of Transportation.  U.S. Department of Transportation (DOT) grants and State 

funding have been used to eliminate unneeded crossings, channelize intersections, install 

four‐quadrant gates, and demonstrate additional risk‐reduction strategies.  Work 

accomplished by North Carolina and States such as Illinois and Michigan charts the future 

direction for other HSR corridors, and data derived from quiet zones employing 

Supplementary Safety Measures supports that direction. 

The Sealed Corridor Study.   FRA’s Office of Research and Development (R&D) tasked the 

Research and Innovative Technology Administration=s (RITA) John A. Volpe National 

Transportation Systems Center (Volpe Center) to document the further success of the 

Sealed Corridor project through Phases I, II and III.  The Sealed Corridor is the section of 

the designated Southeast High‐Speed Rail Corridor that runs through North Carolina.  The 

Sealed Corridor project improved or consolidated every highway‐rail grade crossing, 

public and private, along the Charlotte‐to‐Raleigh rail route in North Carolina.  The initial 

assessment of this HSR corridor as mandated by Congress was published in 2001.  In 2008, 

FRA updated its assessment, comparing the results from a partial Phase I implementation 

to the results of completing Phases I, II, and III.  The research on the Sealed Corridor 

assesses the progress made at the 189 crossings that have been treated with improved 

warning devices or closed between Charlotte and Raleigh from March 1995 through 

September 2004.  

Two approaches are used to describe benefits in terms of Alives saved@: (1) Fatal crash 

analysis to derive lives saved, and (2) prediction of lives saved based on the reduction of 

risk at the treated crossings.  Both methods estimate that over 10 lives would be saved as a 
10 

result of the 189 improvements implemented through December 2004.  Analysis also 

shows that the resulting reduction in accidents due to the crossing improvements is 

sustainable through the year 2010, when anticipated exposure and train speeds along the 

corridor will be increased.  In order to estimate future incident reduction rates and to 

estimate that the reduction result was sustainable, the Modified U.S. DOT Accident 

Prediction Formula was used to ensure that increases in train and vehicle exposure over 

time were considered in the analysis.  

The resulting analysis estimated that the fatality rate resulting from full implementation of 

the entire sealed corridor would be half of the estimated fatality rate if no implementation 

was executed and speed increased to 110 mph.    

Supplementary Safety Measures (SSMs).  To maintain grade crossing safety when 

permitting quiet zones, Federal regulations require adding SSMs to the highway‐rail grade 

crossings within the quiet zones.  SSMs are deterrents; they are additional treatments that 

can be applied to grade crossings that will reduce the number of grade crossing violations.  

If adequate measures are taken to promote safety, high‐speed rail operations, like quiet 

zones, will not compromise safety.   

   

Proposed Policy.  New high‐speed rail operations will require enhanced grade crossing 

safety standards to maintain or enhance the level of safety demonstrated by conventional 

speed operations.  To address the greater risks associated with higher train speeds, FRA 

has developed four safety principles:  

1. Eliminate all redundant or unnecessary crossings together with any crossings that 

cannot be made safe due to crossing geometry or proximity of complex highway 

intersections.  

2. Install the most sophisticated traffic control/warning devices compatible with the 

location (e.g., median barriers, special signage (possible active advanced warning), 

four‐quadrant gates) where train‐operating speeds are between 80 and 110 mph.   

3. Protect rail movement with full width barriers capable of absorbing the impact of 

highway vehicles where train‐operating speeds are between 111 and 125 mph.   

4. Eliminate or grade‐separate all crossings where trains travel at speeds above 125 

mph.   

In addition to aligning with the Track Safety Standards as referenced above, these 

principles are supported by FRA’s Sealed Corridor Study, the School Street Study, and an 

equitable review of the effectiveness of SSMs required for quiet zones.  Both the studies 

and the implementation of SSM for quiet zones address limited operational characteristics. 

 FRA will be conducting further studies to confirm the effectiveness of these principles in 

additional operating environments. 

Available technology may provide additional opportunities for risk reduction on high‐

speed corridors.  For instance, Amtrak’s Incremental Train Control System in Michigan 
11 

provides a mechanism for each train to establish communication with each successive 

crossing to verify the health of the warning system and to verify that the crossing gates 

have descended.  If a negative response or no response is received, the train experiences an 

enforcement that significantly reduces the speed prior to its arrival on the crossing.  This 

system offers the additional advantage of providing a “pre‐start” capability that 

compensates for increased train speed without needing to greatly extend train detection 

circuits. 

On Amtrak’s Northeast Corridor, four‐quadrant gate installations with presence detection 

communicate with the cab signal system and cause a penalty brake application for the 

approaching train if a motor vehicle is detected on the crossing following the descent of the 

gates.  This technology is plausible on the Northeast Corridor because of the relatively 

small number of crossings involved, the predominance of passenger traffic, and heavy rail 

traffic that supported the necessary investment.  

The technology deployed in Michigan and on the Northeast Corridor offers significant 

advantages as well as challenges.  On lines carrying long, heavy freight trains, care must be 

taken to ensure that the locomotive engineer remains in control of the train and that 

temporary obstructions do not lead to reactive braking that could cause undesirable in‐

train forces.  Communications‐based train control technology of the kind likely to be 

employed on Emerging HSR corridors could be arranged to meet these needs, but because 

most freight locomotives are used over extensive portions of the national rail system, 

interoperability would be a major concern. 

Other approaches to reducing the risk posed by grade crossings on high‐speed rail 

corridors also deserve consideration.  Industry has suggested that limiting new crossings 

for corridors where train speed exceeds 110 mph may be appropriate, a suggestion 

underscored by the dearth of demonstrated safeguards.  Other suggestions include placing 

a ceiling on the number of crossings per mile or requiring crossings to be closed when 

acceptable alternative crossings are available or when the crossings per mile exceed the 

standards.  FRA intends to consider all of these suggestions as it moves forward with 

reviewing safety on HSR corridors.  The Guidelines issued with this document will identify 

the apparent safety floor appropriate under the described circumstances.  However, the 

discussion and identification of additional mitigations would likely be based on a case‐by‐

case assessment and a system approach that considers the environment and all the 

features of the proposed system.  

Coincident with issuance of this Strategy, FRA is providing initial Highway­Rail Crossing

Guidelines for High­Speed Passenger Rail that take into consideration stakeholder

comments and will update and refine that guidance as further experience is acquired.  FRA

will also review the success of safety enhancements on designated HSR corridors in Illinois,

Michigan, and Pennsylvania in connection with the Sealed Corridor Study and provide a

report of the findings for use by those planning the details of HSR systems.
12 

d.  Maintenance­of­Way Safety Management  

FRA has given significant attention to Roadway Worker Protection, appropriately 

emphasizing the importance of providing for on‐track safety for those inspecting and 

maintaining track and structures.  The other aspect of this safety interface is ensuring that 

track is not disturbed ahead of train movements, that heavy on‐track maintenance 

equipment is routed away from and kept clear of live tracks except when authorized to be 

there, and that maintenance equipment such as cranes that have the potential to foul live 

tracks during maintenance activities do not do so while trains are passing.   

This issue is an important one on any railroad and, accordingly, is addressed in the 

operating and maintenance rules of the respective railroads.  However, in HSR territory, 

the issue is even more important.  HSR operations present additional risks to roadway 

workers because of the train speed and greater potential risk to workers on adjacent 

tracks.  Adequate distance between track centers, or compensating safeguards, must be 

established to ensure employee safety for day‐to‐day work activities and decrease the 

chance of disruption.   Existing railroad operation and maintenance rules may require 

adjustment to compensate for track curvature or geographic characteristics to further 

reduce any risk to workers.  Integration of roadway worker safety and train control can 

create efficiencies that protect workers while preserving capacity. 

For the present, safety systems such as PTC will not be sufficiently capable in most cases to 

address this type of hazard.  Maintenance‐of‐way (MOW) equipment generally does not 

reliably shunt signal systems, and for the present, signal track circuits will be used by PTC 

to detect track occupancy and to stop trains short of equipment obstructing the track 

ahead.  None of the railroads’ current plans include equipping MOW equipment with PTC, 

although one freight railroad is utilizing a Hi‐Rail Limits Compliance System for inspection 

vehicles that will be able to interface with PTC.  Clearly, in developing PTC architectures for 

entirely new, dedicated HSR systems, attention should be given to identifying work 

equipment and personnel as “targets” to be protected by the PTC system. 

The presence of MOW equipment either occupying the wrong track or fouling an adjacent 

track has been the cause of serious accidents in the past.  If HSR is to be a success, more 

rigorous and effective means will be required to separate train operations from MOW 

activities.  In corridors where there is dedicated passenger service, track maintenance will 

likely be scheduled during times in which no trains are operating, which will enhance 

safety.  

FRA will develop guidelines for MOW safety management, which will be considered in

reviewing system safety programs.
13 

e.  Right­of­Way Safety   

Section 213.361 of the Track Safety Standards requires that, for Class 8 and 9 track (speeds 

exceeding 125 mph), the track owner must submit for approval a “right‐of‐way plan” for 

the prevention of— 

(a) Vandalism 

(b) Launching of objects from overhead bridges or structures into the path of trains 

(c) Intrusion of vehicles from adjacent rights‐of‐way. 

Although these requirements are fundamentally sound, they also apply at lesser speeds.  

Further, even at Class 8 and 9 speeds, questions will arise regarding what undertakings are 

fully responsive and appropriate.  In addition, the existing provision does not refer to all 

relevant threats from outside the operating envelope. 

Many HSR lines may be constructed in common corridors with freight or conventional 

passenger operations.  Maintaining appropriate separation of the two forms of rail service 

will be critical, particularly where there is the potential for a freight train or its cargo to 

foul the high‐speed track(s) or for a highway‐rail grade crossing collision to cause a 

secondary impact between the high‐speed train and other rail equipment.  A variety of 

strategies can be brought to bear to mitigate these risks, all of which should be documented 

in a Right‐of‐Way (ROW) Safety Plan. 

   

With the congestion in cities and the challenges associated with condemning property to 

build new rail lines, it is inevitable that some new railroads will share rights‐of‐way with 

interstate highways.  For example, an HSR operation plans to share the Interstate 15 

corridor from Victorville, California, to Las Vegas, Nevada, with train speeds up to 150 mph. 

As FRA works with this potential applicant for a waiver of passenger equipment structural 

standards, the agency has noted that there is little information available on how to safely 

integrate a highway system with a railroad system on the same right‐of‐way.  The main 

issue is intrusion of highway vehicles on the railroad.  (The issue is relevant beyond HSR as 

the New Mexico Rail Runner Express (Rail Runner) commuter rail operation between 

Albuquerque and Santa Fe, New Mexico uses the median of Interstate 25.  The standards 

used for application of guardrails or other intrusion protection for Rail Runner are the 

same standards that the Federal Highway Administration uses when there is nothing in the 

median.  In other words, there are no special provisions for a highway/railroad shared 

corridor.  Rail Runner started service to Santa Fe in December 2008, and has already had 

some incidents.  For instance, an automobile recently ended up on the tracks when the 

driver lost control while trying to avoid hitting a coyote. )  

There is also a related issue involving highway overpasses.  Even if all grade crossings are 

eliminated, there is still the risk of a car or truck falling from an overpass and landing on 

the track.  The European railroads use intrusion detection nets and other devices on their 
14 

HSR lines to protect their rights‐of‐way at overpasses.  In the United States, pedestrian 

pathways or bicycle trails are sometimes located along with existing rail corridors.   

Limitations on the location of these public access trails should also be addressed to restrict 

access to the HSR line and reduce risk from both safety and security perspectives. 

These strategies must be studied and evaluated.  Intrusion mitigation techniques should be 

developed for incorporation into standards and eventually, into regulations. 

Other issues involving external impacts on the operating environment include seismic 

events, high winds, high water, and landslides.  These conditions are of greater or lesser 

interest depending upon site‐specific factors and should be addressed expressly in an 

expanded ROW Safety Plan for each HSR system. 

FRA will develop vehicle intrusion standards and standards for sharing rail/rail and

highway/rail corridors for incorporation into regulations and/or funding guidance.  FRA will

detail additional hazards that must be evaluated and mitigated based on corridor­specific

risks.

  

f.  Real­Time System Monitoring  

A variety of technologies are now available to monitor the health and performance of the 

railroad operating system in real time (continuously).  Examples include onboard sensors, 

wayside detection devices and autonomous track geometry systems.  These technologies 

should be evaluated for suitability in light of total residual risk as determined in system 

safety program planning. 

FRA will develop an evaluation method to prompt thorough hazard analysis and mitigation

planning for HSR systems.

2. Mitigation

a.  Structural Standards

In the creation of an HSR network in the United States, it must be recognized that there are 

real differences between the American rail system and those found in other countries with 

HSR.  Specifically, in the major countries that have pioneered HSR, the rail systems have 

traditionally been devoted primarily to passenger rail.  As such, there are also three major 

characteristics that have made it easier to implement HSR systems in these countries.  

First, there have been fewer freight trains to deal with.  Second, the freight trains (and 

particularly the motive power) are considerably smaller and lighter in weight than North 

American freight trains.  Third, these rail systems do not have as many grade crossing 

issues: they have fewer highway‐rail grade crossings (level crossings), the crossings are 

used by lighter trucks than those prevalent in the United States, and the respective 
15 

populations have shown greater compliance with warning systems than is typically 

experienced in the United States. 

Despite the differences noted above, FRA is in a good position to implement a sound safety 

regime for an HSR system.  It is nevertheless important to recognize that while the North 

American freight network is the envy of the world, the fact that this network will also be 

the home of Emerging HSR and potentially more aggressive forms of HSR means that safety 

concerns will only increase if no action is taken to mitigate this risk.   

This potential will be significantly reduced as PTC is deployed.  To be sure, the need for 

reasonably crashworthy rolling stock remains an issue where local switching occurs, where 

multiple track operations create the potential for secondary collisions, where the potential 

for on‐track maintenance vehicles to occupy live tracks exists, where MOW safety 

management cannot be fully guaranteed, and where highway‐rail crossings remain that 

might be fouled by large trucks posing the potential for a derailment (with or without a 

secondary collision). 

The Passenger Equipment Safety Standards presently describe only two tiers of equipment. 

Tier I equipment is equipment expected to be used in conventional passenger service, as 

well as HSR to 125 mph, on the general freight system.  Tier II equipment is also designed 

for the general freight system, with speeds up to 150 mph.  Many have noted that these 

standards are not aligned with service needs for higher‐speed operations and for 

operations outside the freight network.  Indeed, when FRA has been challenged to offer 

options for HSR–Express in the past, the agency has recognized the appropriateness of 

considering the type of equipment as an element in the larger operating system (see, e.g., 

notice of proposed rule of particular applicability for Florida Overland eXpress (FOX), 62 

FR 65478, Dec. 12, 1997).  That approach is characterized by the importation of the entire 

system in which the equipment operates for use in a wholly separate system, and not 

simply permitting noncompliant equipment to operate in a typical North American railroad 

setting.  Unfortunately, the inability of successive HSR – Express projects to find stable 

funding has arrested development of a consistent approach to this challenge.   

Since that timeframe, significant advances have occurred in numerical modeling, 

engineering design experience and fabrication techniques.  Such advances currently allow 

for significantly enhanced engineering analyses to be conducted with the potential 

application to comprehensive performance standards that directly address mitigation of 

prevalent scenarios of concern for different types of operating environments.  The key 

metrics of success of such standards are a minimum safe closing speed for which an impact 

can occur where no intrusion into the occupied volume is allowed, and the forces that crew 

members and passengers are subjected to are minimized to survivable levels. 

Europe and Asia have embraced the use of hybrid performance and prescriptive standards 

for commuter railroads, intercity travel, and high‐speed rail.  International systems make 

use of complimentary risk reduction measures including advanced signal systems to 
16 

provide for a high degree of collision avoidance with minimum levels of crashworthiness 

performance.  FRA is currently assessing the variations in performance associated with 

several international passenger safety standards, advances in domestic specifications for 

new car procurements, and explanations for why such variations exist—such as significant 

differences in the operational environment and use of advanced collision avoidance 

technologies.   

The present national commitment to high‐speed rail brings with it a new opportunity to 

create greater predictability in how FRA will approach these issues.  In order to identify 

opportunities for more closely tailored safety standards, FRA proposes to explore the 

possibility of describing a new tiered series of standards for the entire operating system, 

including equipment, in lieu of the current two‐tiered structure that focuses on equipment 

only.  These tiers could categorize methods of operation in conjunction with safety 

improvements such as separation of passenger and freight traffic and advanced train 

control systems.  One of the challenges of a multi‐tiered approach is downward 

compatibility of equipment.  For example, would it be permissible to operate HSR express 

equipment at lower speeds without providing dedicated track and in the presence of 

highway‐rail grade crossings?  Configurations of equipment that may provide safe service 

at high speeds may not always provide safe operation in other environment.  Therefore, 

FRA proposes to handle these anomalies on a case by case basis fully considering the 

environment and the attributes of the system.  Therefore, operating authorities and car 

builders that wish to use alternatively designed equipment that cannot meet the current 

crashworthiness standards or new tier requirements will likely have to make use of the 

waiver process, but the structure for assessing equivalency of safety can be used as the 

means for removing the risk and uncertainty that such organizations otherwise would 

experience. 

New tiered standards, or technical benchmarks to be used in lieu of standards, would 

describe a range of operating environments and, for each such environments, would 

specify— 

 Basic end strength and crash energy management performance in longitudinal 

encounters. 

 Other structural characteristics (e.g., side strength, roof strength as a function of 

vehicle weight).  

 Fixture securement. 

 Acceptable occupant accelerations and restraint strategies based on expected 

vehicle performance. 

In order for this effort to be successful, FRA needs to complete its work on passenger car 

end strength as applied to conventional North American equipment designed for use on the 

general freight rail system.  This amendment to the Passenger Equipment Safety Standards 
17 

will complete the structural benchmarks against which other options can be evaluated.  

Based on an RSAC proposal and an FRA adaptation designed to provide greater design 

flexibility, FRA published a proposed rule on end strength on August 1, 2007 (72 FR 

42016).  The RSAC has made recommendations for a final rule that FRA will issue before 

the end of calendar year 2009.   

FRA will finalize the pending cab end strength rule.  FRA has initiated and will complete an

effort within the RSAC to develop technical criteria and procedures for demonstrating that

equipment built to alternative designs will provide safety equivalent to that provided by

equipment compliant with Tier I standards under 49 CFR Part 238.  Thereafter, FRA will

examine the feasibility of codifying the criteria and procedures and describing additional tiers

of equipment within the standards based on service conditions.

b.  Cab Car Forward   

New standards or guidelines could also address circumstances under which the use of 

passenger‐occupied lead units may or may not be acceptable.  FRA=s regulations for Tier II 

operations, which covers passenger trains that operate up to 150 mph, requires that the 

power cars at the ends of the train exclude passengers.  This is the current arrangement of 

the Acela trainset on the Northeast Corridor.  One HSR operation that will be constructed 

on a dedicated right‐of‐way has proposed a 150 mph service with passenger seating in the 

power cars (cab cars).  Another HSR operation has proposed a 220 mph service and has 

also included passenger seating in the power cars (cab cars). 

FRA realizes that some of the more modern HSR train sets used overseas eliminate the 

conventional power car and use an electrical multiple‐unit configuration that includes 

passenger seating in the cab car.  However, there are no simple answers to the question of 

whether passenger seating in cab cars is appropriate.  The answer will require careful 

research and full consideration of the operating environment where the trainset operates.  

Protection for the operator and passengers will remain a key factor. 

FRA will conduct further research into the relationship between occupied power cars and the

number of injuries and fatalities that might occur in a collision or derailment as part of this

review.

c.  Fuel Tank Integrity   

Finally, some HSR projects may make use of diesel multiple‐unit (DMU) rail cars.  FRA’s 

current fuel tank standards are derived from freight standards (49 CFR § 238.223), and 

arguments have been advanced that a more flexible approach should be taken for tanks 

positioned in such a way as to be better protected.    

FRA will complete research into adaptation of fuel tank safety standards for self­powered

DMU rail cars and propose tailored standards if warranted.
18 

3.  Emergency Management 

All public transportation services rely on emergency preparedness and response to limit 

the adverse effects of accidents and other emergencies.  In 1998, FRA issued a final rule on 

Passenger Train Emergency Preparedness (49 CFR Part 239), the declared purpose of 

which is to reduce the magnitude and severity of casualties in railroad operations by 

ensuring that railroads involved in passenger train operations can effectively and 

efficiently manage passenger train emergencies.  Part 239 prescribes standards for the 

preparation, adoption, and implementation of emergency preparedness plans.  Since that 

time, the RSAC and the American Public Transportation Association’s Passenger Rail 

Equipment Safety Standards Task Force have generated a series of proposed and final 

standards and recommended practices to ensure that appropriate emergency systems and 

procedures are in place.4     

FRA will publish a second NPRM based on RSAC recommendations concerning refinement of

requirements for onboard emergency systems and finalize the rulemaking as soon as possible.

4.  System Safety Programs  

System safety programs (SSPs) seek to integrate the process of identifying safety needs and 

managing them over time.  One key to success is effective hazard identification, which 

focuses attention on opportunities for risk reduction in the particular circumstances of the 

specific passenger railroad.   

Working with the RSAC, FRA is drafting a proposed rule that will require each HSR, 

intercity, and commuter passenger railroad, together with any other railroads engaged in 

joint operations, to develop and implement a documented SSP.  Host railroads, contract 

operators, shared track/corridor operators, and others who provide safety sensitive 

services to the operating railroads shall have defined roles in the passenger railroad SSP.  

The purpose of an SSP is to improve railroad safety through a structured, proactive 

program developed and implemented by passenger railroad operators.  The program 

described in this section can support continuous safety improvement for passengers, 

employees and the public at large.  The SSP can also support development of a strong safety 

culture and requires processes and procedures to identify and manage hazards inherent to 

the passenger railroad.  The proposal would require the SSP to:  

 Be defined and documented through a written System Safety Program Plan that 

meets the standards set forth in this section and is approved by FRA. 

 Include hazard management processes designed to proactively identify, assess, and 

mitigate hazards before accidents occur.   

                                                       

4  See, e.g., 73 FR 6370, Feb. 1, 2008 (Passenger Train Emergency Systems; Emergency Communication, 

Emergency Egress, and Rescue Access; Final Rule). 
19 

 Be fully implemented by the passenger railroad. 

 Be audited for compliance by the passenger railroad and FRA or FRA’s designee. 

   

Generally, the SSP can be used in conjunction with minimum safety standards to increase 

safety.  A system safety approach can bridge gaps in disciplinary knowledge and practice, 

completing the whole.  For instance, station platforms are designed with capacity and 

accessibility in mind.  However, straight platforms are also critical to managing the “gap,” 

and passenger information and warning systems may be required to alert waiting 

passengers to the passage of high‐speed express trains.  Only by envisioning the operation 

of the high‐speed railroad and considering the “what ifs” can initial system design provide 

the predicates for effective safety management.  

Certain operations that are sufficiently isolated and present peculiar operation‐related 

safety concerns may rely more heavily on a tailored system safety approach, particularly if 

a substantially similar operation exists and has operated safely.  For example, in the late 

1990s, FOX planned to utilize the French TGV (“train à grande vitesse” or “high‐speed 

train”) system in Florida.  FRA’s NPRM for FOX included a heavy reliance on SSP planning 

and management. 

FRA will propose to require that scheduled passenger operations establish and maintain SSPs

and include FRA review and approval of management decisions for HSR systems where it is

necessary to determine an appropriate level of safety.
20 

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21 

Next Steps    

In short, FRA believes that a modern HSR rail system that is safe both for riders and 

communities across the country, operating with an appropriate safety regime coupled with 

rigorous oversight, can become a reality.     

More specifically, FRA will address prevention, mitigation, emergency management, and 

system safety integration through the steps set forth above.  FRA will structure a new, 

tiered approach to passenger operations, taking into account maximum operating speeds 

as well as right‐of‐way characteristics, safety technology, planning requirements, and the 

presence or absence of less‐compatible rail traffic (i.e., passenger equipment built to 

different standards or freight operations).  As these actions are being completed, FRA will 

continue to respond to specific passenger rail projects by identifying the information and 

analysis required to evaluate and act on petitions for rules of particular applicability and 

waivers required to facilitate the introduction of innovative HSR service. 
22 

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23 

Appendix A: Current Requirements and Open Issues

 80-110 111-125 126-150/1601 151-200+ 

Track Class 5, 62 Class 7 Class 8 Class 9 

Passenger 

equipment 

Tier I Tier II [Guidance 

needed] 

Passengeroccupied 

vehicle leading 

Permitted Prohibited by 

238.403(f) 

[Guidance 

needed] 

Signal and train 

control3 

PTC – vitality and perimeter 

protection required above 90 mph 

PTC – incursion 

strategy 

integrated 

PTC – system 

safety plan 

integrated

Highway-rail 

grade crossings 

[Guidance 

needed] 

Barrier systems 

required under 

213.247 

Prohibited per 213.347 

MOW safety 

management 

[Guidance 

needed] 

[Guidance 

needed] 

[Guidance 

needed] 

[Guidance 

needed] 

ROW incursion 

prevention / 

detection 

[Guidance 

needed] 

[Guidance 

needed] 

Required 

236.361 

Required 

236.361 

System safety 

program 

[Guidance 

needed] 

[Guidance 

needed] 

Subpart G, Part 

238

[Guidance 

needed] 

 1/ The Track Safety Standards presently allow speeds to 160 mph for Class 8 track.  

 2/ The present track standards treat Class 6 speeds as the lower end of high‐speed track.  

Cant deficiency qualification is easier at higher speeds than at lower speeds because of 

formalized procedures in place for high‐speed track.  This is under review.    

 3/ PTC final rule forthcoming. 
24 

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Appendix B: Potential Tier Structure for Passenger System

(Note: Common corridor issues handled within ROW Safety Plan review)

Tier 0 IA IB IC II III Description Regional rail Conventional Emerging HSR HSR Regional HSR Mixed 

Operations 

HSR Mixed Passenger 

HS

Speed Range mph 

0-65 0-79 0- 80/110 0- 111/125 0-126/150 0-150 0-1

Other traffic on same track 

None (or temporally separated) 

Mixed passenger and freight 

Mixed passenger and freight 

Mixed passenger and freight 

Mixed passenger and freight 

Conventional passenger only 

No

Track class - Class 4 - Class 4 - Class 5/6 - Class 7 - Class 8 - Class 8 - CSignals, train control 

Traffic control PTC PTC; vital and 

perimeter protection above 90 

PTC; vital and perimeter protection above 90 

Per IC and ROW safety strategy integrated 

Public highwayrail grade crossings 

Automated warning; supplementary measures where warranted 

Automated warning; supplementary measures where warranted 

Sealed corridor; evaluate need for presence detection and PTC feedback 

Barriers above 110, see §213.247; Presence detection tied to PTC above 110 

See IC None above 125 

See IC None above 125 

Nospe

Private highway-rail grade crossings 

Automated warning or manually locked gate preferred; cross-buck and stop or yield sign where conditions permit 

Automated warning or locked gate with signal interlock 

None or as above 

None above 125 None above 125 No

spe

ROW safety plan 

System Safety Program / Collision Hazard Analysis SSP/CHA and specific approval process for n

MOW safety management plan 

Address within SSP framework; no separate approval required Separate plan approval; integrate with SSP/C

Equipment CEM – end 

frame strength dynamic test 

Present Tier I plus Cab End Frame Strength, or equivalent safety (including option for alternative to buff strength) 

Present Tier II (including option for alternative to buff strength) 

See Tier IA-C Def

Occupied car forward 

OK OK Prohibited Up to 125 mph 

only 

OK 

On-board emergency systems 

Per Parts 238 and 239 (including glazing, emergency egress and rescue access, lighting, signage

System Safety Programs 

Required; Review is for completeness; Audits for follow through Integrate 

Subpart G, Part 238 

Required; FRA review

25